basic data report for well plugging and abandonment and

DOE/WIPP-05-3326

Basic Data Reportfor Well Plugging and Abandonment and

Reconfiguration Activities forFiscal Year 2005

Waste Isolation Pilot Plant

U.S. Department of EnergyCarlsbad Field Office

Revision 1

September 2008

This document supersedes DOE/WIPP-05-3326.

Basic Data Report for Well Plugging and Abandonment andReconfiguration Activities for Fiscal Year 2005

DOE/WIPP-05-3326, Rev. 1

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This document has been submitted as required to:

Office of Scientific and Technical InformationP.O. Box 62

Oak Ridge, TN 37831(865) 576-8401

Additional information about this document may be obtained by calling the WIPPInformation Center at 1-800-336-9477. Copies may be obtained by contacting theNational Technical Information Service, U.S. Department of Commerce,5285 Port Royal Road, Springfield, VA 22101.

Processing and final preparation of this report was performed by the Waste IsolationPilot Plant Management and Operating Contractor for the U.S. Department of Energyunder Contract No. DE-AC04-29AL66444.



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Basic Data ReportFor Well Plugging and Abandonment and

Reconfiguration Activities for Fiscal Year 2005

Waste Isolation Pilot Plant

Richard A. SalnessWashington Regulatory and Environmental Services

P.O. Box 2078Carlsbad, NM 88220

September 2008



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TABLE OF CONTENTS

LIST OF FIGURES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

ABBREVIATIONS AND ACRONYMS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

1.0 INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

2.0 PROGRAM METHODOLOGY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 92.1 Removal of Well Appurtenances - Retrieval Tools . . . . . . . . . . . . . . . . 112.2 Casing Preparation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 112.3 Well Circulation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 112.4 Well Cementing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 122.5 Well Monuments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 122.6 Well Head Alterations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 122.7 Contractors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

3.0 FISCAL YEAR 2005 WELL P&A AND RECONFIGURATION PROGRAMWASTE MANAGEMENT PRACTICES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

4.0 REGULATORY ISSUES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

5.0 WELL AEC-8 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

6.0 H-2 WELL PAD . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 176.1 Well H-2a . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 176.2 Well H-2b1 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 216.3 Well H-2b2 and Well H-2c . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

7.0 WELL H-14 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

8.0 WELL H-18 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29

9.0 WELL H-4C . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34

10.0 WELL H-7B2 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38

11.0 WELL WIPP-29 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38

12.0 H-6 WELL PAD . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4512.1 Well H-6a . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4512.2 Well H-6c . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49

13.0 H-11 WELL PAD . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5313.1 Well H-11b2 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5313.2 Well H-11b1 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53



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14.0 WELL WIPP-21 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60

15.0 WELL WIPP-22 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60

16.0 WELL WIPP-18 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 67

17.0 H-5 WELL PAD . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6717.1 Well H-5c . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7217.2 Well H-5a . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 72

18.0 H-3 WELL PAD . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7818.1 Well H-3b3 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7818.2 Well H-3b1 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7818.3 Well H-3d . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 83

19.0 WELL WIPP-12 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 86

Appendix A - Photographs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 95



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LIST OF FIGURES

Figure 1 - WIPP Location in Southeastern New Mexico . . . . . . . . . . . . . . . . . . . . 10

Figure 2 - AEC-8 Location Map . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

Figure 3 - Configuration of AEC-8 Before P&A . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

Figure 4 - Configuration of AEC-8 After P&A . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

Figure 5 - H-2 Well Pad Location Map . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

Figure 6 - Construction of Well H-2a Before P&A . . . . . . . . . . . . . . . . . . . . . . . . . 20

Figure 7 - Construction of Well H-2a After P&A . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

Figure 8 - Construction of Well H-2b1 Before Reconfiguration . . . . . . . . . . . . . . . 23

Figure 9 - Construction of Well H-2b1 After Reconfiguration . . . . . . . . . . . . . . . . . 25

Figure 10 - Construction of Well H-2c Before P&A . . . . . . . . . . . . . . . . . . . . . . . . . 26

Figure 11 - Construction of Well H-2c After P&A . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

Figure 12 - H-14 Well Pad Location Map . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

Figure 13 - H-14 Construction Before Reconfiguration . . . . . . . . . . . . . . . . . . . . . . 30

Figure 14 - Construction of Well H-14 After Reconfiguration . . . . . . . . . . . . . . . . . . 31

Figure 15 - H-18 Location Map . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32

Figure 16 - Construction of Well H-18 Before Reconfiguration . . . . . . . . . . . . . . . . 33

Figure 17 - Construction of Well H-18 After Reconfiguration . . . . . . . . . . . . . . . . . . 35


Figure 19 - Construction of Well H-4c Before Reconfiguration . . . . . . . . . . . . . . . . 37

Figure 20 - Construction of Well H-4c After Reconfiguration . . . . . . . . . . . . . . . . . . 39


Figure 22 - Configuration of Well H-7b2 Before P&A . . . . . . . . . . . . . . . . . . . . . . . . 41

Figure 23 - Configuration of Well H-7b2 After P&A . . . . . . . . . . . . . . . . . . . . . . . . . 42

Figure 24 - WIPP-29 Location Map . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43

Figure 25 - Configuration of Well WIPP-29 Before P&A . . . . . . . . . . . . . . . . . . . . . 44

Figure 26 - Configuration of Well WIPP-29 After P&A . . . . . . . . . . . . . . . . . . . . . . . 46


Figure 28 - Construction of Well H-6a Before P&A . . . . . . . . . . . . . . . . . . . . . . . . . 48

Figure 29 - Construction of Well H-6a After P&A . . . . . . . . . . . . . . . . . . . . . . . . . . . 50




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Figure 32 - H-11 Well Pad Location Map . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 55

Figure 33 - Construction of Well H-11b2 Before Reconfiguration . . . . . . . . . . . . . . 56

Figure 34 - Construction of Well H-11b2 After Reconfiguration . . . . . . . . . . . . . . . . 57

Figure 35 - Construction of Well H-11b1 Before P&A . . . . . . . . . . . . . . . . . . . . . . . 58

Figure 36 - Construction of Well H-11b1 After P&A . . . . . . . . . . . . . . . . . . . . . . . . . 59


Figure 38 - Configuration of Well WIPP-21 Before P&A . . . . . . . . . . . . . . . . . . . . . 61

Figure 39 - Configuration of Well WIPP-21 After P&A . . . . . . . . . . . . . . . . . . . . . . . 63


Figure 41 - Construction of Well WIPP-22 Before P&A . . . . . . . . . . . . . . . . . . . . . . 65

Figure 42 - Construction of Well WIPP-22 After P&A . . . . . . . . . . . . . . . . . . . . . . . 66


Figure 44 - Construction of Well WIPP-18 Before Reconfiguration . . . . . . . . . . . . . 69

Figure 45 - Construction of Well WIPP-18 After Reconfiguration . . . . . . . . . . . . . . 70




Figure 49 - Configuration of Well H-5a Before P&A . . . . . . . . . . . . . . . . . . . . . . . . . 76

Figure 50 - Configuration of Well H-5a After P&A . . . . . . . . . . . . . . . . . . . . . . . . . . 77


Figure 52 - Construction of Well H-3b3 Before P&A . . . . . . . . . . . . . . . . . . . . . . . . 80

Figure 53 - Construction of Well H-3b3 After P&A . . . . . . . . . . . . . . . . . . . . . . . . . . 81

Figure 54 - Construction of Well H-3b1 Before Reconfiguration . . . . . . . . . . . . . . . 82

Figure 55 - Construction of Well H-3b1 After Reconfiguration . . . . . . . . . . . . . . . . . 84

Figure 56 - Construction of Well H-3d Before Reconfiguration . . . . . . . . . . . . . . . . 85

Figure 57 - Construction of Well H-3d After Reconfiguration (Large Scale) . . . . . . 88

Figure 58 - Construction of Well H-3d After Reconfiguration (Detail) . . . . . . . . . . . 89


Figure 60 - Construction of WIPP-12 Before P&A . . . . . . . . . . . . . . . . . . . . . . . . . . 91

Figure 61 - Construction of WIPP-12 After P&A . . . . . . . . . . . . . . . . . . . . . . . . . . . 92



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ABBREVIATIONS AND ACRONYMS

AMSL above mean sea level

bgs below ground surfaceBLM U.S. Bureau of Land ManagementBOP blowout preventer

CBFO Carlsbad Field Office (DOE)

DOE U.S. Department of Energy

FY fiscal year

H2S hydrogen sulfide gas

NMED New Mexico Environment DepartmentNMOCD New Mexico Oil and Gas Conservation DivisionNMOSE New Mexico Office of the State Engineer

P&A plugging and abandonmentPIP production-injection packer

RCRA Resource Conservation and Recovery Act

SNL Sandia National Laboratories

TCLP Toxicity Characteristic Leaching Procedure

WIPP Waste Isolation Pilot Plant



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1.0 INTRODUCTION

The Waste Isolation Pilot Plant (WIPP) is a U.S. Department of Energy (DOE) facilitydisposing of transuranic and mixed waste under a permit issued by the New MexicoEnvironment Department (NMED). WIPP is located 26 miles east of Carlsbad,New Mexico, in eastern Eddy County (Figure 1). Disposal panels are mined in thePermian Salado Formation at a depth of about 2,150 feet below ground surface (bgs).

Over the years a number of groundwater monitor wells have been installed for sitecharacterization and to monitor temporal and spatial changes in groundwater elevationand chemistry at WIPP. Many of the wells in the fiscal year (FY) 2005 program wereselected for plugging and abandonment (P&A) due to redundancy. In other words, thewell pads have multiple wells that monitor the Culebra ("Culebra") Member of theRustler Formation when only one is necessary. These multi-well locations are a relic ofvarious aquifer testing programs associated with the site characterization of WIPP. Additionally, the multi-well locations had wells that were completed in both the Culebraand the Magenta ("Magenta") Members of the Rustler Formation for dual monitoring ofthese intervals. The intervals were separated by inflatable packers used as bridgeplugs, and over the years these packers have aged and their integrity compromised. For these wells, the packers were removed and the wells were converted toMagenta-only monitor wells.

The FY 2005 program was initiated on March 31, 2005, and concluded on July 16,2005. The FY 2005 program initially included 25 wells requiring workover (P&A,Magenta reconfiguration, cleaning and keeping). During the process, the U.S. Bureauof Land Management (BLM) requested transfer of two wells (H-7c and H-8c) to theirownership for future livestock watering. These wells were transferred to the BLMthrough execution of Form wr-03, Declaration of Owner of Underground Water Rights,between the New Mexico Office of the State Engineer (NMOSE), the BLM, and the DOECarlsbad Field Office (CBFO). One well (H-2b2) was cleaned and retained as aCulebra monitor well for continued use. One well (H-3d) was converted to a shallowwell to monitor the formational contact between the Dewey Lake Redbeds Formationand the Santa Rosa Formation in support of the DP-831 discharge permit monitoringprogram. Nine dual-completion wells were reconfigured as Magenta-only monitor wells,and 12 wells were plugged and abandoned permanently.

This report presents the summary in the same order that the wells were worked in thefield.

2.0 PROGRAM METHODOLOGY

For this program, the general process for each type of work was identical betweenwells. All wells were processed by first removing all appurtenances, like tubing,packers, bridge plugs, and in some cases old testing equipment and associatedtransducer wires. All wells were scraped to remove oxidation scale from the casing toallow a good bond between the casing and cement.



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Figure 1 - WIPP Location in Southeastern New Mexico



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After scraping, the wells were circulated to remove all debris from the well to the totaldepth, followed by cementing. The following sections describe the general process. Individual well sections describe specific nuances and problems encountered during theprocess.

2.1 Removal of Well Appurtenances - Retrieval Tools

Not all the wells contained packers, bridge plugs, and/or forgotten testing equipment,but in most wells there was equipment of some sort that needed removal. For somewells, the process was simple and the equipment was removed without incident. Forothers, because of equipment age or the age of the well, difficulties were encounteredand in some cases packers were driven to the bottom of the well and cemented in withpermission of the NMOSE.

In some cases, inflatable packers were attached to 2.375-inch tubing or 1.5-inch pipe. Removal of packers in this type of configuration involved attaching the tubing to thedrilling rig elevators and pulling on the tubing to release the packer pressure. Once thepacker was released, the tubing was removed one joint at a time until the packer wasremoved from the well at the surface.

Some wells had inflatable packers that were set in the wells without tubing. For thesecases, the packers were released and removed from the well using retrieval tools, suchas J-hooks, or a combination overshot and grapples. The tools were similar to thoseoriginally used to set the plug, and were attached to the drill rig 2.875-inch tubing onejoint at a time until reaching the packer. The J-tool then was inserted over the packerand turned until latching onto the packer lugs. Once attached, the packer pressure wasreleased and the packer removed from the well.

2.2 Casing Preparation

Some wells in the FY 2005 program were totally cased to the bottom of the well, whilesome were only partially cased. To ensure the well casing was cleaned of residue andscale, each were scraped using various sizes of Weatherford Type E casing scrapers(Photo 1) in Appendix A. The scraper was attached to the drill rig tubing (2.875-inch)and placed into the well one tubing joint at a time. At each tubing joint interval the toolwas moved up and down the full length of the tubing joint for at least three passes oruntil there was no longer any resistance from the tool and casing. This process wasrepeated for the entire length of the casing for each applicable well.

2.3 Well Circulation

After scraping, the debris needed to be removed from the well to the total depth First,the well was fitted with a flow nipple to direct circulated water into a tub for collection. Then the well was circulated by using the 2.875-inch tubing as a tremmie pipe installedinto the well until the top of the collected debris was encountered. The tremmie pipewas plumbed to the drill rig pumps that were plumbed to a freshwater transport truck.



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Water was circulated into the hole through the tremmie pipe and flowed out of the holeat the surface via a well mounted flow nipple. The circulated water and debris werecaptured at the surface by a tub, then pumped into a storage tank (Photo 2). The wellwas circulated until clear return water appeared at the surface. At this point, the wellwas ready for cement.

2.4 Well Cementing

After the well appurtenances were removed from the well and the existing casing wasscraped to remove scale, the scraping tool was removed from the hole and the hole wasreentered with tremmie pipe (2-3/8 inch upset pipe) to the total depth of the hole. Thetremmie pipe was then pulled back so that the open end was eight to ten feet from totaldepth. At this point the hole was filled with Portland cement slurry mixed with fresh|water (Photo 3) in a ratio of 19 sacks of cement to 7 gallons of fresh water yielding27 cubic feet of cement slurry.

All cement was brought on-site by cement trucks where the cement was either pouredinto a tub or directly into a grout pump (Photo 4). For deep wells, the cement waspoured into a tub and extracted via the drill rig pumps and into the tremmie pipes to thebottom of the hole. For shallow wells, the grout pump transported the cement slurrydirectly to the tremmie pipe. Each cement truck emptied approximately one half of eachload into the hole before any tremmie pipe was removed, thus submergingapproximately 300 feet of pipe (10 joints), ensuring a continuous plug from bottom of thehole to the surface. This process was followed until all cement was placed into the hole. Cement quantities placed throughout this program closely matched the theoreticalcalculated borehole volume, indicating no significant voids in the cement and no largeopenings in the uncased formations.

2.5 Well Monuments

The BLM requires that wells permanently abandoned be marked with a monument. Themonument must be at least four inches in diameter and long enough to include thefollowing information welded onto the steel: County, Section, Township, Range,NMOSE #, WIPP, and the BLM right-of-way reservation number. These monumentsmust also be painted per BLM Visual Contrast requirements. At the time of thisprogram, the monuments were required to be desert tan if no more active wells were onthe pad, and blue if there were still wells on the pad that were being used for monitoring. For an example of one painted desert tan, see Photo 15.

2.6 Well Head Alterations

Certain well heads were altered (cut, welded flow nipples, etc.) on wells that werereconfigured for future use as Magenta wells. This affected the top of casing(measuring point) elevation for water level measurements.



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The affected wells and revised reference point elevations are shown in Table 1.

Table 1 - Revised Top of Casing Elevations

Well I.D. Top of Casing Elevation(feet amsl*)

Surface Elevation (feet amsl)

WIPP-18 3,457.74 3,456H-3d 3,390.71 3,387

H-3b1 3,390.68 3,389H-2b1 3,378.47 3,378H-2b2 3,378.31 3,377H-14 3,347.13 3,346H-4c 3,334.09 3,334

H-11b2 3,411.91 3,411H-5c 3,506.06 3,506H-18 3,414.27 3,413H-6c 3,348.52 3,348

* above mean sea level

2.7 Contractors

Washington Regulatory and Environmental Services, an affiliate of Washington TRUSolutions LLC, managed this program, which included technical, regulatory, contracts,financial, and field oversight.

The prime subcontractor was Stewart Brothers Drilling Company of Milan, New Mexico. Stewart Brothers employed Weatherford Tools of Hobbs, New Mexico; SouthwestSafety Specialists, Inc. of Hobbs, New Mexico; Schlumberger of Hobbs, New Mexico,for geophysics, and LaFarge and Southwest Ready Mix, both of Carlsbad, New Mexico,for cement.

3.0 FISCAL YEAR 2005 WELL P&A AND RECONFIGURATION PROGRAMWASTE MANAGEMENT PRACTICES

During P&A and reconfiguration activities, native brine water in the borehole wasdisplaced to the surface. The water was captured from the wellhead casing through aright-angle flow nipple at the surface, then into a tub. A transfer pump moved the waterfrom the tub into a 500-barrel tank for storage prior to disposal. The captured water wascharacterized for disposal by analysis using Toxicity Characteristic Leaching Procedure(TCLP). The TCLP analyses were performed for Resource Conservation and RecoveryAct (RCRA) metals. For all water, the analyses (whether by well or well composites)indicated that the brine water was not a hazardous waste. Following receipt of theanalytical results, the brine water collected from the wells was disposed of at SundanceServices, Inc. in Eunice, New Mexico.



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Trash and debris from construction (i.e., old cement) were disposed of in a centralizedopen-top dumpster located on the H-3 well pad. After the FY 2005 program wascompleted, the trash was disposed of at Lea Land Inc.

4.0 REGULATORY ISSUES

For these wells, the NMOSE had regulatory primacy over P&A and reconfigurationactivities. The NMOSE Roswell Representative was briefed during each well pluggingactivity and made frequent visits to observe the cementing process while plugging thewells. The NMOSE was always consulted during this program when the plannedactivities for a well changed. Plans were typically changed when a packer, tubing, orother down-hole equipment could not be taken out of the well and needed to be left inthe well when cementing. For all cases where "equipment" was cemented in the hole,prior approval from the NMOSE was obtained before completion. Within ten days afterthe activities occurred at each well, a NMOSE Form wr-20, New Mexico Office of theState Engineer Well Record, was completed and submitted by Stewart Brothers to theNMOSE to document the activities.

The BLM and the New Mexico Oil and Gas Conservation Division (NMOCD) wereconsulted on this project to obtain a variance from using brine-saturated cement whenplugging well WIPP-12. Both regulatory agencies cited that it was acceptable to usefresh water to mix Portland cement for the purpose of plugging. Additionally, the|NMOCD claimed that regulatory responsibilities for water wells were not within theirjurisdiction. Based on these waivers from the regulatory agencies, well WIPP-12 wasplugged using a freshwater mix of Portland cement.|

5.0 WELL AEC-8

Well AEC-8 is located approximately one mile northeast of the northeastern corner ofthe WIPP site boundary in Section 11, Township 21 south, Range 31 east (Figure 2). AEC-8 was originally drilled to a depth of 3,019 feet bgs in 1974, and deepened to4,910 feet bgs in 1976 (Figure 3). The borehole was cased with a 5.5-inch casing stringto a depth of 4,907 feet bgs. After deepening, a production-injection packer (PIP) wasset in the casing at 4,825.5 feet (center) on 2.375-inch tubing to monitor theBell Canyon Formation through two sets of perforations from 4,810 to 4,816 feet bgsand from 4,832 to 4,845 feet bgs (Sandia National Laboratories [SNL] and D'AppoloniaConsulting Engineers 1983).

The goal for well AEC-8 was to plug and abandon the well. Work on this well began onMarch 31, 2005, and concluded on April 6, 2005. The workover activities began withthe removal of the valve head and flare lines at the well head, remnants of the initialinstallation of the well. Removal of the packer and tubing were performed as describedin Section 2.0 of this report. This packer and tubing removal process was performedwithout incident.



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Figure 2 - AEC-8 Location Map



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Figure 3 - Configuration of AEC-8 Before P&A



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One hundred fifty-eight (158) joints (sections) of 2.375-inch tubing were removed fromthe well along with the packer. In addition to the removed equipment described above,two old pressure transducers attached to the packer and the associated cable and wiresfor each transducer were also removed estimated at 5,000 feet per transducer(Photo 5). The transducers were permanently fixed to the packer when it was installedby SNL for continuous monitoring. After removal, the transducers were returned to SNLfor historic preservation. The cable and wire were transported to the dumpster locatedat the H-3 well pad for future disposal.

The well was prepared for cementing after the well appurtenances were removed. Scraping was performed as described in Section 2.0 of the report to the total depth ofcasing, 4,907 feet bgs. The well was then circulated with fresh water until the returnwas clean. Upon completion of circulation, the well was cemented to the surface asdescribed in Section 2.0 of this report. A total of 702 cubic feet of Portland cement|slurry was used to plug the well to the surface. Upon completion of the cementing, awell monument was fixed to the well location in accordance to BLM requirements(Figure 4) (Photo 6).

6.0 H-2 WELL PAD

The H-2 hydropad consisted of one well completed in the Magenta Member of theRustler Formation (H-2b1) and three wells completed in the Culebra Member of theRustler Formation (H-2a, H-2b2, and H-2c) (Stensrud et al., 1988a). The pad nowconsists of one Magenta well and one Culebra well after plugging and reconfigurationefforts. This pad is located approximately 0.75 mile southwest of the center of WIPP. Itis located in Section 29, Township 22 South, and Range 31 East (Figure 5).

The scope of work at this hydropad was to plug one of two wells completed in theCulebra (H-2b2 or H-2c) and plug H-2a because it had a pump in the bottom of the well,lost during a sampling event. In addition to the activities listed above for the H-2 wellpad, the scope of work also included plugging back well H-2b1 to below the existingMagenta perforations.

6.1 Well H-2a

Well H-2a was originally drilled to a total depth of 563 feet bgs and cased to a depth of511 feet bgs. The hole was later deepened to 616 feet bgs and cored to 672 feet bgs. In 1984, the hole was reentered and completed with a screen across the Culebra(Figure 6) (Stensrud et al., 1988a). During a well sampling event, a Bennett pneumaticpump and packer assembly was dropped into the well and jammed itself into the well atthe bottom of the casing at a depth of 605 feet bgs. Attempts were made to retrieve thepump, but all were unsuccessful.



18

Figure 4 - Configuration of AEC-8 After P&A



19Figure 5 - H-2 Well Pad Location Map



20

Figure 6 - Construction of Well H-2a Before P&A



21

The NMOSE was consulted regarding the condition of this hole before attempting toretrieve the lost pump in the well. Through these discussions, the NMOSE approvedleaving the pump in the well and cementing it in as long as the pump is driven into thewell as far as possible. After this change in scope, the well was scraped and circulatedas described in Section 2.0 of this report. Following casing preparation, the pump wasdriven from 605 feet bgs to a depth of 610 feet bgs, gaining 5 feet. The pump wasdriven into the lead packer and screen (Figure 7).

Upon completion of circulation, the well was cemented to the surface as described inSection 2.0 of this report. A total of 81 cubic feet of Portland cement slurry was used to|plug the well to the surface. After cementing, a well monument was fixed to the welllocation in accordance to BLM requirements (Figure 7). Work on this well concluded onApril 7, 2005, one day after starting.

6.2 Well H-2b1

Well H-2b1 was being used to monitor hydrostatic head in the Magenta Member of theRustler Formation. Well H-2b1 was drilled in February 1977 to a total depth of 661 feetbgs and cased with 6.625-inch casing to the top of the Culebra Member of the RustlerFormation at a depth of 609 feet bgs. The interval between 510 and 538 feet was latershot-perforated to access the Magenta Member of the Rustler Formation. A packer wasset at a depth of 578 feet bgs to isolate the Culebra (Figure 8) (Stensrud et al., 1988a).

The goal for well H-2b1 was to remove the packer, plug the well back to below theMagenta perforations, and use it as only a Magenta monitoring well. Work on this wellbegan on April 12, 2005, and concluded on April 16, 2005. The work over activitiesbegan with scraping the well casing to the top of the packer and circulating the debrisout of the well. A J-tool was used for the removal of the packer as described inSection 2.0 of this report. The packer was not removed. After latching onto the packerwith the J-tool, the drill rig applied pressure to pull it out of the well. After severalminutes of applied pressure, the packer separated where the J-tool attaches to thepacker lugs, on top of the mandrel (Photos 7 and 8). After inspection of the packermandrel head, it was apparent that metal fatigue was the reason for the failure.

After attempting removal with a J-tool, the decision was made to remove the packerusing an overshot and grapple tool since the lugs were broken off the mandrel. Usingthe overshot was successful at moving the top of the packer from 589 feet bgs to446 feet bgs before getting stuck. The packer would not move at all beyond this pointafter several attempts. Contact was made with the NMOSE to authorize driving thepacker as deep as possible and cementing it in the well. The NMOSE did authorizecementing the packer into the well as long as the packer was driven as deep aspossible into the well.



22

Figure 7 - Construction of Well H-2a After P&A



23

Figure 8 - Construction of Well H-2b1 Before Reconfiguration



24

Stacked drill collars were used at the end of the tremmie tubing to drive the packer backdown the hole. Ten 4.75-inch collars were used to drive the packer to a final depth of603 feet bgs, measuring to the top of the remaining mandrel. This effectively provided aseal above the Culebra for the cement emplacement. After driving with the collars, theremaining casing was scraped and the well was circulated preparing the well forcement. The well was cemented to a depth of 558 feet bgs using 10.5 cubic feet ofPortland cement slurry. This elevation is 20 feet below the Magenta perforations|allowing future Magenta monitoring at this location (Figure 9).

6.3 Well H-2b2 and Well H-2c

The goal between these two wells was first to determine which well was in bettercondition and keep the best well for future monitoring, while plugging the worst well andremoving it from the monitoring network. Well H-2b2 was drilled in 1982 to a depth of660 feet bgs for monitoring the Culebra. In 1984, due to hole instability, a well screenwas placed across the Culebra to keep the unit open to monitoring. Well H-2c wasoriginally drilled in 1977 to a depth of 795 feet bgs, and cased to the top of theRustler/Salado contact at 792 feet bgs with 6.625-inch OD, J-55 casing. A 5.375-inchOD packer was set at 663 feet bgs to isolate the Culebra. The casing was perforatedacross the Culebra interval (Figure 10) (Stensrud et al., 1988a).

To determine which well was the better of the two wells, borehole geophysicaltechniques were used. Each well was scraped and circulated on April 17, 2005. Following well preparation, each well was evaluated using a cement bond log andcasing corrosion log. Based on these logs and collaboration with SNL, it wasdetermined that well H-2c was in worse condition and required plugging. Well H-2b2was retained as a Culebra monitoring well, leaving the H-2 well pad with one Culebraand one Magenta well for monitoring.

Prior to scraping and circulating well H-2c, the packer set at 663 feet bgs was removedusing a J-tool. The packer was removed without incident and, following evaluation ofthe geophysics, this well was plugged using 162 cubic feet of Portland cement slurry. |Upon completion of the cementing, a well monument was fixed to the well location inaccordance to BLM requirements (Figure 11).

7.0 WELL H-14

Well H-14 is located in eastern Eddy County, New Mexico in the southwest quarter,Section 29, Township 22 South, Range 31 East (Figure 12). The drilling of the boreholewas performed during September and October 1986 to a depth of 589 feet. Afterdrilling, 5.5-inch casing was set and cemented from 532 feet bgs to the surface. A4.5-inch hole was then cored through the Culebra to 574 feet bgs. The open portion ofthe well was then reamed to a 4.75-inch diameter and deepened to a final depth of 589feet bgs (Stensrud et al., 1987).



25

Figure 9 - Construction of Well H-2b1 After Reconfiguration



26

Figure 10 - Construction of Well H-2c Before P&A



27

Figure 11 - Construction of Well H-2c After P&A



28

Figure 12 - H-14 Well Pad Location Map



29

In March 2001, the well was fitted with an inflatable bridge plug (PIP) at a depth of465.78 feet bgs, just below the Magenta Member. Following the installation of thebridge plug, the well was perforated at the Magenta interval from 428 to 455 feet bgs(Figure 13). Well H-14 was used to monitor hydrostatic head in the Magenta Member ofthe Rustler Formation in this configuration. The objective under this program was toreconfigure well H-14 as a Magenta-only monitor well.

Reconfiguration of well H-14 took place between April 21, 2005, and April 27, 2005. The casing was scraped and the well circulated to the top of the packer. Severalunsuccessful attempts were made to retrieve the packer using a J-tool and two sizes ofovershot and grapple tools. After the attempts at removing the packer with the standardtools, a decision was made to use a spear to fish out the packer (Photo 9).

The packer was removed with the spear without any problems. After the packer wasremoved, it was discovered that the packer was an odd size and not configured forremoval with the tools being used. Following packer removal, the remainder of thecasing was scraped to a depth of 532 feet bgs and the well circulated. After circulation,the well was reconfigured by cementing to a depth of 468 feet bgs, 20 feet below theMagenta perforations, using 23.75 cubic feet of Portland cement slurry (Figure 14).|

8.0 WELL H-18

Well H-18 is located in Eddy County, New Mexico in Section 20, Township 22 South,Range 31 East (Figure 15). Well H-18 was drilled in October 1987 to define hydrologicproperties of the Culebra. After being cored and reamed to a 9.625-inch diameter holeto 674 feet bgs, 7-inch casing was installed and cemented to 673 feet bgs. The holewas then cored and reamed to 4.75-inch diameter to a depth of 714.1 feet bgs. Afterfurther borehole testing, the hole was deepened and reamed to a total depth of 840 feetbgs. A cement plug was placed in well H-18 from the total depth to 766 feet bgs(Figure 16) (Stensrud et al., 1988b).

In March 2001, the well was fitted with an inflatable bridge plug (PIP) at a depth of613.08 feet bgs, just below the Magenta Member. Following the installation of thebridge plug, the well was perforated at the Magenta interval from 575 to 601 feet bgs(Figure 16).

Well H-18 was a dual-completion well used to monitor hydrostatic head in the MagentaMember of the Rustler Formation. The objective under the FY 2005 program was toreconfigure well H-18 as a Magenta-only monitor well.

Reconfiguration of well H-18 took place between April 27, 2005, and April 30, 2005. The casing was scraped and the well circulated to the top of the packer. Severalattempts were made to retrieve the packer using a J-tool. After attempting to removethe packer with a J-tool and using knowledge gained at well H-14, a decision was madeto use a spear to fish out the packer (Photo 10).



30

Figure 13 - H-14 Construction Before Reconfiguration



31

Figure 14 - Construction of Well H-14 After Reconfiguration



32

Figure 15 - H-18 Location Map



33

Figure 16 - Construction of Well H-18 Before Reconfiguration



34

The packer was removed with the spear without any problems. Following packerremoval, the remainder of the casing was scraped to a depth of 673 feet bgs and thewell circulated. After circulation, the well was reconfigured by cementing the well to adepth of 615 feet bgs with 40.5 cubic feet Portland cement slurry (Figure 17).|

9.0 WELL H-4C

Well H-4c is located in eastern Eddy County, New Mexico in the southwest quarter,Section 32, Township 22 South, Range 31 East (Figure 18). Well H-4c was originallydrilled in 1978 to test and monitor the Rustler/Salado contact. A 7.875-inch boreholewas drilled to a depth of 610 feet bgs and completed with 5.5-inch casing to a depth of610 feet bgs. The casing was then cemented to the surface. The borehole was thencored at a diameter of 4.75-inches from 610 feet to 661 feet bgs, forty feet into theSalado Formation. In February 1981, a retrievable bridge plug was set in the casing ata depth of 530 feet bgs. The casing was then shot-perforated from 494 to 520 feet bgsto access the Culebra (Stensrud et al., 1987).

In 1986, the well was reentered to complete a monitoring interval across the MagentaMember of the Rustler Formation. First, a 4.25-inch Baker Production Bridge Plug wasinstalled in the well at a depth of 435.07 feet bgs to the top of the packer. Following thepacker installation, the Magenta dolomite interval was perforated from 373 to 399 feetbgs (Figure 19).

Well H-4c was a dual-completion well used to monitor hydrostatic head in the MagentaMember of the Rustler Formation. The objective under this program was to reconfigurewell H-4c as a single-completion Magenta-only monitor well. At the time ofreconfiguration, this well was completed with two packers used to separatewater-bearing zones.

The first task was to remove the upper packer by scraping and circulating down to thetop of the mandrel. Once the initial scraping was accomplished, the packer was readyfor removal. First a J-tool was used to remove the packer. This was successful untilthe packer reached a depth of 120 feet bgs, where the packer got stuck in the well. Multiple tools were tried in sequence for an attempted retrieval. At this depth, significantpressure was applied by the drilling rig to extract the packer. Rig pressure was notenough to move the packer. In an attempt to move the packer past this point, a bumpersub with hydraulic jars and drill collars were used to "jerk" the packer from this staticposition. Using this set up, the packer moved a small amount before it separated at theelement (Photos 11 and 12).

An attempt was made to drill the packer element and mandrel assembly to loosen itfrom the well, which was not successful. At this point, the NMOSE was consulted andsuggested that the packer be driven to the bottom of the well, on top of the lowerpacker. To do this, 18 drill collars and a bumper sub were used increasing the stringweight of the rig to 17,000 pounds. The upper packer was then driven to a depth of513.5 feet bgs, in the lower portion of the Culebra perforations.



35

Figure 17 - Construction of Well H-18 After Reconfiguration



36Figure 18 - H-4 Well Pad Location Map



37

Figure 19 - Construction of Well H-4c Before Reconfiguration



38

The well was scraped from 435 feet bgs to the top of the upper packer followed by wellcirculation. After circulation, the well was cemented from total depth to a depth of415 feet bgs with 19 cubic feet of Portland cement slurry (Figure 20).|

10.0 WELL H-7B2

This well is located approximately six miles southwest of the center of the WIPP site inSection 14, Township 23 South, and Range 30 East (Figure 21). The configuration ofthe H-7 hydropad consisted of one well completed in the Magenta Member of theRustler Formation (H-7a) and three wells completed in the Culebra Member of theRustler Formation (H-7b, H-7b2, and H-7c) (SNL and Intera Technologies 1986).

The original scope of work at this hydropad was to plug two wells completed in theCulebra (H-7b2 and H-7c). During the process, the BLM requested transfer of well H-7cto their ownership for future livestock watering programs. This well was transferred tothe BLM through execution of Form wr-03, Declaration of Owner of Underground WaterRights, between the NMOSE, the BLM, and the DOE CBFO.

The P&A work at well H-7b2 occurred between May 10-12, 2005. This well wascompleted in the Culebra at a shallow depth of 268 feet bgs (Figure 22). The well wasscraped to the total depth and circulated. While the well was being cleaned out,circulation was lost due to split casing, detected by geophysical analysis in 2002. Toallow sufficient cementing, Baro-Seal™ was used to assist in plugging open spaces(Photo 13). Five bags of Baro-Seal™ was used in conjunction with 148.5 cubic feet ofPortland Cement slurry, filling the well to the surface. Upon completion of the|cementing, a well monument was fixed to the well location in accordance to BLMrequirements (Figure 23).

11.0 WELL WIPP-29

WIPP-29 is located approximately 11 miles from the center of the WIPP site inSection 34, Township 22 South, and Range 29 East (Figure 24). It was drilled in 1978as an exploratory borehole to investigate near-surface formations and the dissolution ofsoluble rock by groundwater. The well was located west of Nash Draw. The boreholefor WIPP-29 was drilled to a depth 377 feet bgs and cased to a depth of 376 feet bgs. The casing was subsequently perforated in the Salado Formation from 216 to 250 feetbgs and the Culebra from 10 to 45 feet bgs. To separate the Culebra from the SaladoFormation perforations, an inflatable packer was installed at 75 feet bgs (Figure 25)(SNL and U.S. Geological Survey 1979). The purpose of WIPP-29 was to monitorhydrostatic head in the Culebra Member. The objective under the FY 2005 programwas to decommission well WIPP-29 and remove it from the monitoring network.



39

Figure 20 - Construction of Well H-4c After Reconfiguration



40




41

Figure 22 - Configuration of Well H-7b2 Before P&A



42

Figure 23 - Configuration of Well H-7b2 After P&A



43

Figure 24 - WIPP-29 Location Map



44

Figure 25 - Configuration of Well WIPP-29 Before P&A



45

Plugging activities at WIPP-29 occurred between May 12-13, 2005. The well wasentered with the tubing and a J-tool to remove the packer. The packer was removedwithout any problems (Photo 14). Following the packer removal the well was scrapedand circulated as described in Section 2.0 of this report. Following scraping the wellwas cemented to the surface with 54 cubic feet of cement filling the well to the surface. Upon completion of the cementing, a well monument was fixed to the well location inaccordance to BLM requirements (Figure 26) (Photo 15).

12.0 H-6 WELL PAD

The H-6 hydropad is located in the northwest corner of Section 18, Township 22 South,Range 31 East, near the northwest corner of the WIPP site (Figure 27). Three wellslocated on the H-6 hydropad, H-6a, H-6b, and H-6c, were drilled and completed in Juneand July of 1978. Well decommissioning and reconfiguration work at this pad occurredfrom May 13-25, 2005.

12.1 Well H-6a

Well H-6a was originally completed with 5.5-inch casing cemented from ground surfaceto 475 feet bgs, and a 4.75-inch open hole to a total depth of 525 feet bgs. In January1981, the well was reentered and drilled and cored to a new depth of 640 feet bgs. APIP was thought to have been installed at a depth of 594 feet bgs on 2.375-inch tubing(Beauheim and Ruskauff 1998). Instead, the PIP was found to be set on 1.5-inch(internal diameter) galvanized pipe at 575 feet bgs (Figure 28). The purpose ofwell H-6a was to monitor hydrostatic head in the Culebra Member. The objective underthe FY 2005 program was to plug and abandon well H-6a and remove it from themonitoring network.

Because the PIP was set on galvanized pipe, removing the PIP assembly (packer andpipe) was difficult due to excessive corrosion. The approach for this well was initiallysimilar to well AEC-8 in which the tubing and packer were to be removed by attachingthe tubing to the drilling rig elevators and pulling on the tubing to release the packerpressure. However, due to the metal fatigue of the pipe threads and the pipe section,the pipe was removed in pieces using an overshot tool and grapple. Additionally,several hundred feet of cable and electrical wire were bound in the hole that maderemoval difficult (Photos 16 and 17).

Virtually all of the galvanized pipe and 356 feet of transducer wire and cable wereremoved from the well but attempts to remove the packer were unsuccessful. Thedecision was then made, and agreed to by the NMOSE, to drive the packer as far aspossible into the well.



46

Figure 26 - Configuration of Well WIPP-29 After P&A



47




48

Figure 28 - Construction of Well H-6a Before P&A



49

Several drill collars were loaded onto the packer inside the well. The maximum depththat could be achieved was 575 feet bgs, representing no incremental progress. Itappeared that rock fall from the open hole below the packer prevented the unit frombeing driven deeper. After attempting to drive the packer, the well was circulated inpreparation for cementing. The well was filled with 83 cubic feet of Portland cement|slurry, filling the well to the surface. Upon completion, of the cementing a wellmonument was fixed to the well location in accordance to BLM requirements(Figure 29).

12.2 Well H-6c

Well H-6c was completed with 5.5-inch casing cemented to a depth of 699 feet bgs anda 4.75-inch open hole to a total depth of 741 feet bgs. In January 1981, the casing inwell H-6c was perforated from 604 to 631 feet bgs to provide communication with theCulebra Member, and a bridge plug was set at 641 feet bgs to separate the Culebrafrom the underlying open portion of the hole (Beauheim and Ruskauff 1998). In 1986,the casing in well H-6c was perforated from 490 to 514 feet bgs and a bridge plugreportedly set at 527 feet bgs to provide communication to the Magenta (Figure 30).

Well H-6c was a dual-completion well used to monitor hydrostatic head in the MagentaMember of the Rustler Formation. The objective under this program was to reconfigurewell H-6c as a Magenta-only monitor well, sealing off the Culebra portion. This well hadtwo inflatable packers being used as bridge plugs to separate the Culebra and MagentaMembers from each other, and the Culebra from the open hole below, respectively. Work began by scraping the upper part of the casing to the top of the upper packer,followed by circulation of the well to remove debris. The upper packer was encounteredat a depth of 524 feet bgs, shallower than documented.

A J-tool was used to remove the upper packer almost without incident. The packer wasremoved from the well, however, one-half of the rubber element stripped from thepacker and remained in the well at a depth of 160 feet. In order to get the rubberelement out of the hole, the drilling contractor fabricated a barbed spear to extract theremaining element from the well (Photo 18). After the element was removed from thewell, the remaining casing was scraped and circulated down to the lower packer at641 feet bgs.

Retrieving the lower packer proved difficult. A J-tool was used to attempt retrieval, butthe packer would not move after several hours. A decision was made, and approved bythe NMOSE, to leave the packer in the hole at a depth of 641 feet bgs. Followingactivities to remove the packers, the well was cemented up to a depth of 534 feet bgs,allowing exposure to the Magenta for monitoring (Figure 31).



50

Figure 29 - Construction of Well H-6a After P&A



51




52




53

13.0 H-11 WELL PAD

The H-11 hydropad is located in Section 33, Township 22 South, Range 31 East,approximately 2.5 miles southeast of the center of the WIPP site (Figure 32). TheH-11 hydropad originally consisted of four wells completed to the Culebra Member ofthe Rustler Formation. These wells are identified as H-11b1, H-11b2, H-11b3, andH-11b4. Wells H-11b1, H-11b2, and H-11b3 were drilled and completed betweenAugust 1983 and January 1984. Well H-11b4 was drilled and completed in 1988(Mercer 1990). Wells H-11b1, H-11b2, and H-11b3 were drilled by first coring throughthe Culebra into the Los Medaños Member of the Rustler Formation, near the top of thehalite in that unit. The boreholes were then reamed to the top of the Culebra and casingwas installed and cemented to provide open-hole access to the Culebra. Well H-11b3was plugged and abandoned in 2002, leaving three Culebra wells on this pad (H-11b1,H-11b2, and H-11b4). The FY 2005 program plugging and reconfiguration activities atthe H-11 well pad occurred May 25-28, 2005.

13.1 Well H-11b2

Well H-11b2 was the first well workover at this pad during the FY 2005 program. Well H-11b2 was completed with 5.5-inch casing cemented to a depth of 733.39 feetbgs and a 4.75-inch open hole to a total depth of 776 feet bgs (Mercer 1990). In March2001, the well was fitted with an inflatable bridge plug (PIP) at a depth of 663.1 feet bgs,just below the Magenta Member. Following the installation of the bridge plug, the wellwas perforated at the Magenta interval from 622 to 650 feet bgs (Figure 33).

The purpose of well H-11b2 was to monitor the hydrostatic head in the MagentaMember of the Rustler Formation. The objective under the FY 2005 program was toplug well H-11b2 back to 670 feet bgs, below the Magenta perforations, so that a bridgeplug is no longer needed to isolate the Magenta from the Culebra.

The packer was removed using a J-tool without any problems (Photo 19). Followingactivities to remove the packer, the well was scraped, circulated, and cemented up to adepth of 670 feet bgs using 14.5 cubic feet of Portland cement slurry, allowing exposure|to the Magenta for monitoring (Figure 34).

13.2 Well H-11b1

Well H-11b1 was completed with 5.5-inch casing cemented from ground surface to732 feet bgs, and a 4.75-inch open hole to a total depth of 785 feet bgs (Mercer 1990). The purpose of well H-11b1 was to monitor the hydrostatic head in the Culebra Memberof the Rustler Formation (Figure 35). The objective under the FY 2005 program was toplug and abandon well H-11b1 and remove it from the monitoring network.

This well was not configured with any packer assembly, so the plugging effort wasstraight forward. The well was scraped and circulated to a depth of 776 feet bgs, ninefeet from the original depth. It was apparent that the bottom of the hole had some rock



54

fall at the base, preventing circulation to the original depth. Following preparation forcementing, the well was filled with 108 cubic feet of Portland cement slurry, filling the|well to the surface. Upon completion of the cementing, a well monument was fixed tothe well location in accordance to BLM requirements (Figure 36).



55




56




57




58

Figure 35 - Construction of Well H-11b1 Before P&A



59

Figure 36 - Construction of Well H-11b1 After P&A



60

14.0 WELL WIPP-21

Well WIPP-21 was located in eastern Eddy County, New Mexico, in the southeastquarter of Section 20, Township 22 South, Range 31 East (Figure 37). The locationwas originally a testing borehole only. It was originally drilled in 1978 to a total depth of1,046 feet bgs, and then loaded with brine mud pending further testing, plugging, orrecompletion. In 1985, the borehole was reentered to complete it as a Culebramonitoring well. Recompletion consisted of cleaning and reaming the hole to adiameter of 7.875 inches to a depth of 868 feet bgs, and cleaning the hole andcementing from 868 feet bgs to total depth (1,046 feet bgs). The well was completedwith 5.5-inch casing to a depth of 868 feet bgs and then perforating the Culebra intervalfrom 727 to 751 feet bgs (Figure 38) (Saulnier et al., 1987).

The purpose of well WIPP-21 was to monitor hydrostatic head in the Culebra Member. The objective under the FY 2005 program was to plug and abandon the well andremove it from the monitoring network. Activities at this well occurred on May 28-29,2005. This well was not configured with any packer assembly, so the plugging effortwas very straight forward. The well was scraped and circulated to a depth of 946 feetbgs, indicating the bottom of the well was not completely filled with cement asdocumented. Following preparation for cementing, the well was filled with 135 cubicfeet of Portland cement slurry, filling the well to the surface. Upon completion of the|cementing, a well monument was fixed to the well location in accordance to BLMrequirements (Figure 39).

15.0 WELL WIPP-22

Well WIPP-22 was located in eastern Eddy County, New Mexico, in the southeastquarter of Section 20, Township 22 South, and Range 31 East (Figure 40). The locationwas originally a testing borehole only. It was originally drilled in 1978 to a total depth of1,452 feet bgs, and then loaded with brine mud pending further testing, plugging, orrecompletion. In 1985, the borehole was reentered to complete it as a Culebramonitoring well. Reconfiguration consisted of cleaning and reaming the hole to adiameter of 7.875-inches to a depth of 950 feet bgs, and cleaning the hole andcementing from 950 feet bgs to total depth (1452 feet bgs). The well was completed bycementing 5.5-inch casing to a depth of 950 feet bgs and then perforating at theCulebra interval from 748 to 770 feet bgs (Figure 41) (Saulnier et al., 1987).

The purpose of well WIPP-22 was to monitor hydrostatic head in the Culebra Member. The objective under the FY 2005 program was to plug and abandon the well andremove it from the monitoring network. Activities at this well occurred on May 29-30,2005. This well was not configured with any packer assembly, so the plugging effortwas very straightforward. The well was scraped and circulated to total depth, 941 feetbgs. Following preparation for cementing, the well was filled with 135 cubic feet ofPortland cement slurry, filling the well to the surface. Upon completion of the|cementing, a well monument was fixed to the well location in accordance to BLMrequirements (Figure 42).



61




62

Figure 38 - Configuration of Well WIPP-21 Before P&A



63

Figure 39 - Configuration of Well WIPP-21 After P&A



64




65

Figure 41 - Construction of Well WIPP-22 Before P&A



66

Figure 42 - Construction of Well WIPP-22 After P&A



67

16.0 WELL WIPP-18

Well WIPP-18 is located in Section 20, Township 22 South, Range 31 East, in easternEddy County, New Mexico and was drilled in March 1978 (Figure 43). The boreholewas drilled to a depth of 1,060 feet bgs. After drilling, the borehole was left open,uncased, and filled with brine or brine mud until 1985. In 1985, the borehole wascleaned and reamed to a 7.875-inches diameter and a 5.5-inch casing was cemented to1,050 feet in the Salado Formation, leaving a cement plug in the bottom of the hole from1,050 to 1,060 feet bgs. After the casing was set, the borehole was perforated from784 to 806 feet bgs. In March 2001, the well was fitted with an inflatable bridge plug(PIP) at a depth of 713.2 feet bgs, just below the Magenta Member. Following theinstallation of the bridge plug, the well was perforated at the Magenta interval from676 to 702 feet bgs (Figure 44) (Saulnier et al., 1987).

Well WIPP-18 was a dual-completion well being used to monitor hydrostatic head in theMagenta Member of the Rustler Formation. The objective under the FY 2005 programwas to reconfigure Well WIPP-18 as a Magenta-only monitor well by removing thepacker and cementing up to the Magenta perforations. The activities for this welloccurred May 30-31, 2005.

The removal of the packer and preparing the well was performed as described inSection 2.0 of this report. The well was first scraped and circulated down to the packerelevation. The packer was removed without incident, then the remaining casing wasscraped and circulated to a depth of 1,050 feet bgs. Following packer removal and wellpreparation, 47.25 cubic feet of cement was pumped into the well to a depth 20 feetbelow the Magenta perforations for continued monitoring of this zone (Figure 45).

17.0 H-5 WELL PAD

The H-5 well pad is located 1,007 feet from the north line, 234 feet from the east line, inSection 15, Township 22 South, Range 31 East in Eddy County, New Mexico(Figure 46). The pad consists of three wells (H-5a, H-5b, and H-5c) that were drilled in1978 and completed in the Culebra Member of the Rustler Formation (Hydro GeoChem, Inc. 1985). Later, well H-5c was reconfigured as a dual-completion well used tomonitor the Magenta. The objective for the FY 2005 program for this pad was to reducethe number of wells at this location to one Culebra well and one Magenta well. Wellplugging and reconfiguration activities at this location occurred May 31-June 11, 2005.



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Figure 44 - Construction of Well WIPP-18 Before Reconfiguration



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Figure 45 - Construction of Well WIPP-18 After Reconfiguration



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17.1 Well H-5c

Well H-5c was completed with 5.5-inch casing cemented to a depth of 1,024 feet bgsand a 4.75-inch open hole to a total depth of 1,076 feet bgs. In 1981, the casing inwell H-5c was perforated from 895 to 925 feet bgs to provide communication with theCulebra, and an inflatable bridge plug was set at 935 feet bgs to separate the Culebrafrom the underlying open portion of the hole (Hydro Geo Chem, Inc. 1985). In 1986, thecasing in well H-5c was perforated from 788 to 812 feet bgs to provide communicationto the Magenta. An inflatable packer was set at 836 feet bgs to separate the Culebrafrom the Magenta (Figure 47).

Well H-5c was used to monitor hydrostatic head in the Magenta Member of the RustlerFormation. The objective under the FY 2005 program was to reconfigure thedual-completion well H-5c as a Magenta-only monitor well. The two packers wereremoved without incident using a J-tool as described in Section 2.0 of this report. Following packer removal and well preparation, 45.15 cubic feet of cement was pumpedinto the well to a depth 20 feet below the Magenta perforations to allow continuedmonitoring of this zone (Figure 48).

17.2 Well H-5a

Well H-5a was completed with 5.5-inch casing cemented in place from ground surfaceto 774 feet bgs. After setting the casing, a 4.75-inch open hole was drilled from 774 feetbgs to 897 feet bgs. A 2.25-inch hole was cored from 897 feet bgs to a total depth of934 feet bgs. Following well construction, an inflatable PIP was set at 895 feet bgs with1.5-inch galvanized tubing extending to the surface (Figure 49) (Hydro Geo Chem, Inc.1985). The purpose of this well was to monitor hydrostatic head in the Culebra. Theobjective under the FY 2005 program was to plug and abandon this well and remove itfrom the monitoring network.

Activities at this well were similar to those at the H-6c location, due to similarconstruction. Because the PIP was set on galvanized pipe instead of steel tubing,removing the PIP assembly (packer and pipe) was difficult due to excessive corrosion. Due to the metal fatigue of the pipe threads and the pipe section, the pipe was removedin pieces using a overshot tool and grapple. Additionally, several hundred feet of cableand electrical wire were bound in the hole that made removal difficult (Photos 20 and21). The packer was moved up to a depth of 474 feet bgs before getting stuck in thewell.

After several attempts to remove the packer and after removal of approximately 777 feetof galvanized pipe and transducer wire and cable, the decision was made, and agreedto by the NMOSE, to drive the packer as far as possible into the well.

Twenty-two drill collars were loaded onto the pipe and packer inside the well and theassembly was driven as far into the well as possible. The maximum depth that could beachieved was 603 feet bgs, estimating the depth of the packer bottom at 897 feet bgs,



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the transition to the 2.25-inch hole. After driving the packer to depth, the well wascirculated in preparation for cementing. The well was filled with 81 cubic feet ofPortland cement slurry, filling the well to the surface. Upon completion of the|cementing, a well monument was fixed to the well location in accordance to BLMrequirements (Figure 50).



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Figure 49 - Configuration of Well H-5a Before P&A



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Figure 50 - Configuration of Well H-5a After P&A



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18.0 H-3 WELL PAD

The H-3 well pad is located approximately one-half mile from the center of the WIPPsite in Section 29, Township 22 South, and Range 31 East (Figure 51). The well padcontained four wells (H-3b1, H-3b2, H-3b3, H-3d) prior to the FY 2005 program. Thesewere completed at various intervals to investigate geologic and hydraulic properties andperform aquifer and tracer testing. Well work-over activities at this location during theFY 2005 program occurred June 11-24, 2005.

18.1 Well H-3b3

Well H-3b3 was drilled in 1983 as an exploratory borehole to investigate hydraulicproperties. The borehole for well H-3b3 was drilled to a depth of 730 feet bgs andcased to a depth of 673 feet bgs (Figure 52) (SNL and Intera Technologies 1986). Theborehole was left open across the Culebra. The purpose of this well was to monitorhydrostatic head in the Culebra. The objective under the FY 2005 program was to plugand abandon well H-3b3 and remove it from the monitoring network.

This well contained no packer or other elements, so the decommissioning process wasstraightforward: scrape, circulate, cement, and monument. Work for this well occurredJune 11-12, 2005.

The well was scraped to a depth of 672 feet bgs as described in Section 2.0 of thisreport. Following scraping, the well was circulated to total depth, followed by cementingthe well to the surface using tremmie pipe as presented in Section 2.0 using 108 cubicfeet of Portland cement slurry, concluding with fixing a monument at the location|according to BLM requirements (Figure 53).

18.2 Well H-3b1

Well H-3b1 was drilled under the direction of the USGS and was completed August 12,1976. This well was drilled to a total depth of 894 feet bgs and completed with6.625-inch casing. The well was subsequently perforated at three different intervals atthe Magenta (564 to 592 feet bgs), the Culebra (675 to 703 feet bgs), and theRustler/Salado Formations contact (813 to 837 feet bgs). The well was then fitted withmechanical bridge plugs separating these intervals (Figure 54) (SNL and InteraTechnologies 1986).

Despite all the different perforated intervals, the Magenta was the only interval beingmonitored before reconfiguring this well. The plan for this well under the FY 2005program was to remove all the bridge plugs and reconfigure the well as asingle-completion location for Magenta monitoring. Work at this well occurredJune 13-14, 2005.



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Figure 52 - Construction of Well H-3b3 Before P&A



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Figure 53 - Construction of Well H-3b3 After P&A



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Two mechanical bridge plugs were removed from this well (Photos 22 and 23). Thewell was scraped down to the first packer (actually at 634 feet bgs) and the spallcirculated from the well. The bridge plug was retrieved using a J-tool as described inSection 2.0 without incident. Following removal of the upper bridge plug, the well wasscraped to the top of the lower bridge plug followed by circulation. The lower bridgeplug was encountered at a depth of 781 feet bgs, not 795 feet bgs as documented. Following retrieval of the lower packer, the remaining casing was scraped and circulatedin preparation for cementing operations. Cement was placed using tremmie methodsas described in Section 2.0. A total of 54 cubic feet of Portland cement slurry was used|to fill the well to a depth of 612 feet bgs (Figure 55).

18.3 Well H-3d

Well H-3d was drilled in April 1987 as an observation well for the Forty-niner Member ofthe Rustler Formation and the Dewey Lake Redbeds. The well was completed bysetting an inflatable packer with tubing in the upper anhydrite of the Forty-niner. Nocasing or well screen were used for well completion, leaving an open hole (Stensrudet al., 1990).

Well H-3d was drilled to a depth of approximately 555 feet bgs in the lower part of theForty-niner Member of the Rustler Formation. After drilling and cleaning the borehole ofcutting, a Baker Service Tools 5.625-inch PIP was installed from 515 to 518 feet bgs inthe upper anhydrite of the Forty-niner Member. Additionally, 419 feet of 0.75-inch PVCtubing was installed in the annulus for water-level access (Figure 56) (Stensrud et al.,1990).

Well H-3d was used as an observation well to monitor the water levels since installation;however, later data indicated that the tubing in the well was pinched. The objectiveunder the FY 2005 program was to remove the PIP assembly (packer and tubing), cleanout the open borehole, cement up to a new well depth, and install a new PVC well at theSanta Rosa/Dewey Lake contact zone. Well reconfiguration at this location occurred intwo stages: June 14-15, 2005 (well clean-out), and June 21-24, 2005 (setting the newwell).

To begin the first phase, the PVC tubing was removed from the well using cable pulleysfrom the drilling rig (Photo 24). Twenty-five 20-foot sections of PVC tubing wereremoved from the borehole (500 linear feet). After removing the PVC tubing, an attemptat removing the 2.375-inch tubing was made. It was obvious why water levels could nolonger be obtained from this location from the onset of removing the tubing.

Initial tubing removal was attempted in the same manner as described for well AEC-8;however, the tubing separated in sections measuring from 6 feet to 6 inches. Thetubing removal was accomplished, for the most part, using an overshot-grapple tool,



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Figure 56 - Construction of Well H-3d Before Reconfiguration



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tripping in and out of the borehole removing sections at a time (Photo 25). During thisprocess, it became apparent that the packer in the hole had failed and dropped furtherdown the hole as the depth of tubing at one point was 528 feet bgs, thirteen feet belowthe reported depth. After fourteen hours over a day and a half, the decision was madeto leave the packer in the hole at a depth of 528 feet bgs. The decision wascoordinated with, and approved with, the NMOSE.

Following removal of the tubing, the borehole was circulated to clean the hole out asbest as possible. Following circulation, the borehole was filled with 162 cubic feet ofcement to a depth of 87 feet bgs. Once the cement was cured, work began oncompleting the well for a Santa Rosa/Dewey Lake monitor well.

The design depth of the new well was based on the Santa Rosa/Dewey Lake contact. This contact was defined by the stratigraphic description provided in Appendix BH of theCompliance Certification Application (U.S. DOE, 1996) for this well and confirmed byDennis Powers, Consulting Geologist; and Rick Beauheim, SNL. The contact wasstraddled with 20 feet of well screen (10 feet above the contact and 10 feet below thecontact) to ensure intersection with this zone. Ten feet of blank casing was installed atthe bottom of the well for a sump to collect well debris and also allow a submersiblepump if one was needed in the future. Final completion of the well is presented inFigures 57 and 58.

19.0 WELL WIPP-12

Well WIPP-12 was drilled in December 1978 in Section 17, Township 22 South, andRange 31 East (Figure 59). The borehole was drilled to a depth of 2,773.3 feet bgs andcompleted with 9.625-inch casing to 1,001.5 feet bgs. In 1981 and 1982, the well wasdeepened through the Castile Formation to a total depth of 3,927.5 feet bgs. Duringdeepening, a pressurized brine reservoir was encountered in the Castile Formation at adepth of 3,016 feet bgs. In 1983, the brine reservoir was sealed from the upper part ofthe borehole by installing a borehole plug from 2,784 to 3,000 feet bgs. The boreholeplug consisted of a bridge plug covered by 27 feet of sand and 189 feet of cement. Theborehole was capped until testing occurred in 1985. Following testing, a retrievablebridge plug was set in the casing below the Culebra interval. The Culebra was thenperforated in 1985 from 815 to 840 feet bgs for monitoring water levels (Figure 60)(Saulnier et al., 1987).

Well WIPP-12 was used to monitor hydrostatic head in the Culebra Member of theRustler Formation. The objective under the FY 2005 program was to plug and abandonwell WIPP-12 and remove it from the monitoring network. P&A activities at WIPP-12occurred during July 12-16, 2005.

When brine was discovered in WIPP-12, associated hydrogen sulfide gas (H2S) wasalso reported to be present. Because of the potential for H2S gas buildup between thelower plug and the upper packer over the decade, extra precautionary measures wereundertaken prior to and during the well plugging activities to protect workers.



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Prior to commencing work at WIPP-12, the comprehensive "Site Safety & HydrogenSulfide (H2S) Work Plan: WIPP Process, Public and Worksite Protection Guide" wasdeveloped. The guide contained specific emergency response planning andimplementation, safety planning and implementation, rescue and first aid, contingencyplanning, and emergency communication planning for the job. Also, the plan containedspecific work scope to follow for a safe operation.

In accordance with the plan, the area was first equipped with proper H2S hazardsignage, wind socks, and a hazmat/rescue trailer that was manned 24 hours a day. Because there was a potential for H2S gas at this location and possible blowout at thewell head, the plan called for preliminary actions for the well itself before the actualP&A. The well was filled with 11 pound brine water to decrease the potential for firehazards. A cellar measuring 6 feet x 6 feet x 4 feet deep was excavated around thewell head. The excavation was then braced with shoring. The well casing was then cutoff 5 feet bgs to allow the blowout preventer (BOP) to be installed. A flange was weldedto the casing, then the BOP was securely bolted to the well head so that if there was arelease of H2S gas it could be shut into the well. The BOP was tested for leaks andproper operation. The drill rig and well were then set up with audible and visual H2S gasmonitors (Photos 26, 27, and 28).

Following the installation of the BOP, the well was scraped to the depth of the packer(984 feet bgs) as described in Section 2.0. This was followed by circulating the well ofdebris until clean return was confirmed. After circulating the well, the packer wasremoved as described in Section 2.0. A kill truck was attached to the BOP in the eventan uncontrollable H2S release occurred when the packer was removed. The kill truckwould allow heavy brine to be pressure pumped into the well forcing the H2S gas backinto the formation, allowing the BOP to be shut-in and prevent a gas release until properflare equipment could be set up. Additionally, all personnel working around the rig andwithin the exclusion zone were required to wear supplied air respirators until the packerwas removed from the well. The packer was removed without incident and no H2S gasor brine was encountered. However, when the packer was released, there was enoughpressure buildup beneath it to force the assembly up approximately three feet in the well(Photos 29 and 30).

Following removal of the packer, the crew removed the supplied air respirators andwork continued under Level D PPE conditions (hard hats, steel toe boots, gloves, safetyglasses) with continuous monitoring and escape packs. Following the packer removal,the remaining casing was scraped and circulated in preparation for cement. The wellwas then circulated to total depth followed by cementing using tremmie pipe asdescribed in Section 2.0. A total of 1,188 cubic feet of Portland cement slurry was used|to plug the well to the surface. Upon completion of cementing, a well monument wasfixed to the well location in accordance to BLM requirements (Figure 61) (Photos 31 and32).



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Figure 57 - Construction of Well H-3d After Reconfiguration (Large Scale)



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Figure 58 - Construction of Well H-3d After Reconfiguration (Detail)



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Figure 60 - Construction of WIPP-12 Before P&A



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Figure 61 - Construction of WIPP-12 After P&A



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REFERENCES

Beauheim, R. L., and G. J. Ruskauff, 1998. Analysis of Hydraulic Tests of the Culebraand Magenta Dolomites and Dewy Lake Redbeds Conducted at the WasteIsolation Pilot Plant Site. SAND98-0049. Albuquerque, NM. Sandia NationalLaboratories.

Hydro Geo Chem, Inc., 1985. WIPP Hydrology Program, Waste Isolation Pilot Plant,SENM, Hydrologic Data Report #1. SAND85-7206. Albuquerque, NM. SandiaNational Laboratories.

Mercer, J. W. 1990. Basic Data Report for Drillholes at the H-11 Complex (WasteIsolation Pilot Plant - WIPP). SAND89-0200.

Saulnier, G. J. Jr., G. A. Freeze, and W. A. Stensrud, 1987. WIPP Hydrology Program,Waste Isolation Pilot Plant, Southeastern New Mexico, Hydrologic Data Report#4. SAND86-7166. Albuquerque, NM. Sandia National Laboratories.

Sandia National Laboratories and United States Geological Survey 1979. Basic DataReport for Drillhole WIPP-29 (Waste Isolation Pilot Plant-WIPP). SAND79-0283. Albuquerque, NM. Sandia National Laboratories.

Sandia National Laboratories and D'Appolonia Consulting Engineers 1983. Basic DataReport fo Drillhole AEC-8, Waste Isolation Pilot Plant - WIPP. SAND79-0269. Albuquerque, NM. Sandia National Laboratories.

Sandia National Laboratories and Intera Technologies, Inc. 1986. WIPP HydrologyProgram Waste Isolation Pilot Plant, Southeastern New Mexico, Hydrologic DataReport #3. SAND86-7109. Albuquerque, NM. Sandia National Laboratories.

Stensrud, W. A., M. A. Bame, K. D. Lantz, J. B. Palmer, and G. J. Saulnier, Jr. 1987.WIPP Hydrology Program, Waste Isolation Pilot Plant, SoutheasternNew Mexico, Hydrologic Data Report #5. SAND87-7125. Albuquerque, NM. Sandia National Laboratories.

Stensrud, W. A., M. A. Bame, K. D. Lantz, T. L. Cauffman, J. B. Palmer, andG. J. Saulnier, Jr. 1988a. WIPP Hydrology Program, Waste Isolation Pilot Plant,Southeastern New Mexico, Hydrologic Data Report #6. SAND87-7166. Albuquerque, NM. Sandia National Laboratories.

Stensrud, W. A., M. A. Bame, K. D. Lantz, J. B. Palmer, and G. J. Saulnier, Jr. 1988b.WIPP Hydrology Program, Waste Isolation Pilot Plant, Southeastern NewMexico, Hydrologic Data Report #7. SAND88-7014. Albuquerque, NM. SandiaNational Laboratories.



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Stensrud, W. A., M. A. Bame, K. D. Lantz, J. B. Palmer, and G. J. Saulnier, Jr. 1990.WIPP Hydrology Program, Waste Isolation Pilot Plant, Southeastern NewMexico, Hydrologic Data Report #8. SAND89-7056. Albuquerque, NM. SandiaNational Laboratories.

Appendix A - Photographs



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Photo 2 - Collection Tub

Photo 1 - Casing Scraper




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Photo 3 - Tremmie Pipe Cement Emplacement

Photo 4 - Cement Truck Pouring Into a Tub




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Photo 6 - Well Monument at AEC-8

Photo 5 - Transducer Cable From Well AEC-8




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Photo 8 - Separated Mandrel at Lugs at H-2b1

Photo 7 - Top of Packer Mandrel Separated at Lugs at H-2b1




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Photo 10 - Spear and Packer at Well H-18

Photo 9 - Spear Removal From Packer at H-14




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Photo 11 - Upper Mandrel Separated at Packer Element - Well H-4c

Photo 12 - Top of Separated Packer Element at Well H-4c




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Photo 14 - Packer Removed From Well WIPP-29

Photo 13 - Baro-Seal™ Used at Well H-7c




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Photo 15 - Monument at WIPP-29

Photo 16 - Galvanized Tubing at H-6a




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Photo 17 - Wire Pulled From Well H-6a

Photo 18 - Spear, Packer, and Element FromWell H-6c




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Photo 19 - J-Tool on Tubing Removing Packer From Well H-11b2




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Photo 21 - Wire Removed From Well H-5a Using Barbed Spear

Photo 20 - Galvanized Tubing From Well H-5a




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Photo 22 - Upper Bridge Plug Being Removed From H-3b1 Using J-Tool




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Photo 24 - PVC Tubing Removed From H-3d

Photo 23 - Well H-3b1 Lower Packer on Pipe Trailer




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Photo 26 - Warning Signs and Barricades at Road Leading to Well WIPP-12

Photo 25 - PVC and Steel Tubing From Well H-3d




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Photo 27 - Haz/Mat Trailer at Command and Control and Access Station forWell WIPP-12

Photo 28 - Shored Cellar and BOP Assembly With Hydraulic Actuator Linesat WIPP-12




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Photo 30 - Contractor Crew on Supplied Air While Removing Packer atWIPP-12

Photo 29 - Kill Truck Assembled to BOP Prior to Packer Removal at WIPP-12




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Photo 32 - Well Monument at WIPP-12

Photo 31 - Packer Removed From WIPP-12 With Kill Truck inBackground. Red Tool Boxes are Escape Packs with30-Minute Supplied Air Escape Bottles and Hoods

basic data report for well plugging and abandonment and

Documents